Last updated 18 October 2026 — by Adrian Tan, SDM. Marketing guidance, not legal advice. Section and regulation numbers refer to the Payment Services Act 2019 and Payment Services Regulations 2019 on Singapore Statutes Online as at 18 October 2026, and paragraph numbers to MAS Notices PSN07 and PSN08 as published by MAS. Check with MAS or a lawyer before relying on any point.
Remittance is one of the most competitive consumer categories in Singapore advertising. Migrant workers send money home every payday, travellers change currency before every holiday, and apps compete for both with “zero fee” and “best rate” offers on Facebook, TikTok, WhatsApp and the side of a bus. For an agency, it looks like any other performance category.
It is not. Remittance, money-changing and e-wallets are payment services under the Payment Services Act 2019 (PSA), and the PSA contains something most consumer regimes do not: a direct ban on advertising an offer of the service unless the provider is licensed or exempt. That ban reaches overseas providers targeting Singapore, and it reaches people in Singapore who advertise on their behalf. On top of it, MAS notices prescribe a statement that licensed providers must put in their marketing, and require exchange rates and fees to be displayed prominently.
This guide is for remittance companies, money-changers, e-wallet and cross-border payment apps, and the agencies, affiliates and influencers that market them. It explains who may advertise, what an advertisement must say, how rates and fees must be shown, and where an agency’s own liability begins. For digital payment tokens, which have their own advertising restrictions, see our guide to crypto marketing in Singapore.
The rules at a glance
| Question | Short answer | Source |
|---|---|---|
| Who may advertise remittance or money-changing? | Only a licensee or an exempt payment service provider, or someone acting for one | PSA s 9; PS Regs reg 30 |
| Does it apply to overseas apps? | Yes, “whether in Singapore or elsewhere”, if the ad is aimed at the public in Singapore | PSA s 9(1); reg 11 |
| Can a Singapore agency run ads for an unlicensed overseas provider? | No; a person in Singapore must not do so on that provider’s behalf | PSA s 9(3) |
| What must a licensee’s marketing say? | A prescribed statement that it is licensed by MAS and what that does not mean | PSN08 paras 4, 5, 11 |
| Must exchange rates be shown? | Yes, prominently, before the customer uses the service, with any separate fee | PSN07 para 16 |
| What is the penalty for advertising without a licence? | Up to $125,000 and/or 3 years for an individual; up to $250,000 for others, plus daily fines | PSA ss 5(3), 9(2), 9(4) |
Remittance and money-changing are licensed activities
Section 5 of the PSA prohibits carrying on a business of providing any type of payment service in Singapore without a licence or an exemption. Cross-border money transfer (remittance), money-changing, domestic money transfer, e-money issuance and digital payment token services are all payment services under the Act.
Section 5(2) closes a common loophole. Offering a payment service alongside another business, such as a minimart that also changes money or a travel agency that also arranges transfers, is presumed to be a separate business of providing that service. It does not help to show that the payment service is related or incidental to the main business.
The penalties under section 5(3) are heavy for a marketing-adjacent offence:
- for an individual, a fine of up to $125,000, imprisonment of up to 3 years, or both, plus up to $12,500 a day for a continuing offence; and
- for any other person, such as a company, a fine of up to $250,000, plus up to $25,000 a day.
Section 8 adds a “holding out” offence. A person must not hold themselves out as carrying on a payment service business unless they are licensed or exempt (s 8(1)(a)), and must not hold themselves out as a licensee without a licence in force (s 8(1)(b)). The same penalties apply (s 8(2)). A shopfront sign reading “Money Changer”, a Facebook page offering “fast transfer to Manila” or a website claiming to be “MAS licensed” are all, potentially, holding out.
The advertising ban: section 9
What section 9 prohibits
Section 9 is headed “Prohibition against solicitation”, and it is the provision that turns a licensing question into an advertising one. Under section 9(1), a person who is not a licensee or an exempt payment service provider, “whether in Singapore or elsewhere”, must not:
- offer, or “issue any advertisement containing any offer” to provide, any payment service to the public in Singapore or any section of the public in Singapore (s 9(1)(a)); or
- make an offer or invitation, or issue such an advertisement, to enter into an agreement for the provision of a payment service (s 9(1)(b)).
The penalties in section 9(2) mirror section 5: up to $125,000 and/or 3 years for an individual, and up to $250,000 for others, with daily fines for continuing offences.
The agency and affiliate limb: section 9(3)
Section 9(3) is the part every agency should read twice. A person in Singapore, even one who is itself licensed, must not make such an offer or issue such an advertisement on behalf of a person who is not licensed or exempt. Section 9(4) applies the same penalties.
In practice, this catches:
- a Singapore agency running Meta or Google campaigns for an overseas remittance app that has no Singapore licence;
- a local influencer posting an affiliate code for that app;
- a Singapore company acting as the “local partner” that places print or outdoor ads; and
- a shop that displays posters offering transfers through an unlicensed provider.
Section 18 adds a related rule for licensees: a licensee must not provide its service through an agent who is not itself licensed or exempt, with a fine of up to $100,000 plus $10,000 a day. A licensed remittance company that uses a network of unlicensed shops to take customers’ money is exposed under section 18, and so may be the shops under section 5.
The publisher’s defence: section 9(6)
Section 9(6) gives a defence to a person who publishes an advertisement in the ordinary course of business. The defence applies if the publisher received the advertisement in the ordinary course of business, did not devise or select its content, and had no reason to believe that publishing it was an offence. This protects a newspaper or a platform that carries an ad it did not create. It is unlikely to protect an agency that wrote the copy, chose the targeting and ran the campaign, because the agency devised the content.
When is an ad aimed at “the public in Singapore”?
Section 9 only bites on offers to the public in Singapore. For an overseas provider, and for any agency running regional campaigns, the question is when an advertisement counts as aimed here. Regulation 11 of the Payment Services Regulations 2019 lists the factors:
| Reg 11 factor | What it means for a campaign |
|---|---|
| (a) Information specifically relevant to Singapore | SGD pricing, Singapore addresses, local phone numbers, references to Singapore events or paydays |
| (b) Media principally for Singapore | Singapore periodicals, broadcasts, websites, apps, posters and brochures |
| (c) to (e) Availability to people in Singapore | Saying e-money or tokens are available here, mentioning SGD e-money, or exchanging tokens for SGD |
| (f) A prominent notice that no service is provided to anyone in Singapore | Whether that notice is seen with or before the ad |
| (g) Reasonable steps to stop Singapore customers signing up | Blocking Singapore sign-ups, IP or phone-number checks |
Read against how paid social works, the factors are demanding. A campaign geo-targeted to Singapore, in Singapore media, quoting SGD rates, is aimed at the public in Singapore on almost every factor. A regional campaign that excludes Singapore from targeting, carries a prominent “not available in Singapore” notice and blocks Singapore sign-ups is on the other side of the line. Most real campaigns sit somewhere in between, which is why the safest course for an agency is simply to confirm the provider’s Singapore licence before taking the brief.
What a licensee’s advertising must say: PSN08
The prescribed statement
MAS Notice PSN08 on Disclosures and Communications (current version effective 4 April 2024) requires licensed and exempt providers to give customers a prescribed statement. For a standard payment institution, paragraph 4 sets out a statement saying that the firm “is licensed by the Monetary Authority of Singapore to provide” the named service, followed by a warning that this “does not mean you will be able to recover all the money you paid” if the business fails. Paragraph 5 provides an equivalent statement for major payment institutions offering money-changing where the deal is not completed immediately, and paragraphs 7 and 8 cover exempt providers. Use the exact wording in the current notice for your provider’s category.
How the statement must appear
Paragraph 11 sets the presentation rules. The statement must be published at least once in material available to the public, and given to the customer before they use the service. It must “not be obstructed or obscured, or embedded within other unrelated writing”, and must be in a “reasonable size and typeface”. A statement buried in a footer, hidden behind a “terms” link, or set in grey six-point type under a bright rate banner does not meet that standard.
Third-party marketers
Paragraphs 15 to 17 deal directly with agencies, affiliates and partners. Every offer or advertisement made by a third party for the licensee’s service must carry the statement, and must make clear that the service is provided by the regulated firm, not by the marketer. An influencer’s post, a comparison site’s listing or a partner bank’s banner promoting a remittance app therefore needs the provider’s name and the statement, not just a referral code.
Describing MAS regulation accurately
Paragraphs 18 and 19 require any statement about the scope of MAS regulation to be “accurate and not false or misleading”. A provider must not overstate which of its activities are licensed, and within a corporate group must make clear which entity holds the licence. Under paragraph 20, if MAS identifies a false or misleading statement by a third party, the licensee must ask that party to correct it. Claims such as “MAS approved”, “regulated and guaranteed” or “your money is 100% safe” deserve particular care: the PSN08 statement exists precisely because a licence does not guarantee that customers will get their money back.
| Ad claim | Problem | Safer approach |
|---|---|---|
| “MAS licensed” with no further detail | Must match the licence held and the entity that holds it | Name the licensed entity and the service, with the PSN08 statement |
| “Your money is fully protected” | Conflicts with the PSN08 warning; overstates safeguarding | Describe the safeguarding method accurately, if the firm is required to safeguard |
| “Regulated by MAS” for a group brand | May imply every group entity is licensed | State which entity holds the licence |
| Referral post without the provider named | Third-party marketers must name the provider and carry the statement | Provider name, statement and disclosure of the paid relationship |
On safeguarding: section 23 of the PSA requires major payment institutions offering domestic transfers, cross-border transfers or merchant acquisition to safeguard customer money by the next business day, through a bank undertaking, a guarantee or a trust account. A provider that is subject to section 23 can describe how it safeguards. That is a long way from “fully protected”, and a standard payment institution that is not subject to it cannot borrow the language at all.
Showing exchange rates and fees: PSN07
“Best rate” and “zero fee” are the two most common claims in remittance and money-changing advertising. MAS Notice PSN07 on Conduct (as amended with effect from 4 October 2024) sets the rules that sit behind them.
Paragraph 16, headed “Display of Exchange Rate and Fees”, requires licensees to display prominently, so that the customer sees it before using the service, the exchange rate offered where a service involves currency conversion, including a money-changer’s rate before the exchange, and any fee charged separately. Paragraph 17 applies a similar duty to exempt providers. Paragraph 9 and Annex B require receipts to show the exchange rate applied and the commission in Singapore dollars, and paragraph 22 requires exchange-rate records to be kept for at least five years. Paragraph 23 requires a licensee’s normal business hours to be published and displayed prominently. Check the notice for the exact activities each limb covers.
For marketers, three consequences follow:
- “Zero fee” must be true of the whole transaction. If the cost sits in the exchange-rate margin, the rate is part of the price, and a “no fees” headline next to an uncompetitive rate risks being misleading under the Consumer Protection (Fair Trading) Act even if no separate fee is charged.
- Advertised rates must be the rates customers get. A rate in an ad should match the rate displayed at the point of service and printed on the receipt, with any conditions, such as minimum amounts or first-transfer offers, stated clearly.
- Records support claims. Because rates must be kept for five years, a “best rate” or “beat any rate” claim can be checked later. Keep the evidence for any comparison the day the ad runs.
How to check a provider before taking the brief
The single most useful control an agency can have is a licence check at onboarding. MAS publishes a Financial Institutions Directory of licensed and exempt firms, and an Investor Alert List of persons “wrongly perceived as being licensed” by MAS. MAS says the alert list “is not exhaustive”, so absence from it proves nothing; presence in the directory, under the right entity name and for the right service, is what counts.
- Search the Financial Institutions Directory for the exact legal entity that will provide the service to Singapore customers.
- Confirm the licence covers the service being advertised, such as cross-border money transfer or money-changing, not just a related activity.
- Check the Investor Alert List for the brand and its app names.
- Get the provider’s current PSN08 statement wording in writing and build it into every template.
- Confirm any agents, partner shops or referral partners named in the campaign are themselves licensed or exempt.
- Keep the check, dated, on the client file.
The check also protects against impersonation. Remittance is a favourite category for scam ads that copy a real provider’s name and logo; our guide to brand impersonation in Singapore covers how legitimate brands can respond.
Channel notes
Paid social and search. Platforms apply their own financial services verification, but platform approval is not a licence check. The PSA question has to be answered before the campaign is built.
WhatsApp and chat apps. Remittance providers often run customer acquisition through WhatsApp groups and broadcast lists in migrant communities. A message offering transfers is an offer of a payment service, so section 9 applies in exactly the same way, and the PDPA and Do Not Call rules apply to the messages themselves. See our guide to WhatsApp marketing in Singapore.
Shopfronts and outdoor. A money-changer’s rate board is both an advertisement and the PSN07 rate display. Keep it current, show any fee, and make sure the business name on the sign matches the licensed entity. Signs offering transfers on behalf of another company are holding out, or agency, problems if that company is not licensed.
Embedded payments. E-commerce and app businesses that add wallets or cross-border payouts sometimes market them as features. If your business is not the licensed provider, say who is. Our guide to payment gateways in Singapore explains the licence categories.
Worked examples
Example 1 — an overseas app wants Singapore installs. A remittance app licensed in another country, but not in Singapore, asks a Singapore agency to run TikTok and Meta campaigns targeting Filipino workers in Singapore. The ads would be aimed at the public in Singapore on most reg 11 factors, so the app cannot lawfully run them, and the agency would be advertising on its behalf from Singapore under section 9(3). Decline the brief until the app shows a Singapore licence or exemption.
Example 2 — a licensed remittance firm’s payday campaign. A licensed major payment institution wants a “zero fees this Sunday” campaign. Compliant execution: name the licensed entity, carry the PSN08 statement in readable type on each ad and landing page, show the exchange rate customers will get, state any minimum amount, and keep the rates and creative on file. If the rate on Sunday is wider than usual, “zero fees” alone is a misleading headline.
Example 3 — an influencer referral programme. A licensed e-wallet wants creators to post referral codes. Each post must name the provider and carry the statement under PSN08 paragraphs 15 to 17, and the paid relationship must be disclosed. Brief creators not to say “MAS guaranteed” or “safer than a bank”.
Conclusion
Remittance and money-changing advertising in Singapore turns on one question: is the provider licensed or exempt for this service? If not, section 9 prohibits the advertising and reaches anyone in Singapore who runs it on the provider’s behalf. If it is, MAS notices set out what the marketing must say, and how rates and fees must be shown. For agencies, the licence check is no longer a compliance nicety. It is the difference between running a campaign and committing an offence with a $250,000 ceiling.
If you market a payment or remittance brand and want campaigns built around these rules from the first brief, our performance marketing team in Singapore can help; see our client case studies for results. For more on regulated financial categories, read our guides to moneylender advertising, credit card, loan and BNPL advertising and investment offer advertising, or start with our complete guide to performance marketing in Singapore.
Frequently asked questions
Can an unlicensed remittance company advertise in Singapore?
No. Section 9 of the Payment Services Act prohibits anyone who is not licensed or exempt, whether in Singapore or elsewhere, from advertising an offer of a payment service to the public in Singapore. Penalties reach $250,000 for companies.
Is a Singapore agency liable for ads it runs for an overseas provider?
It can be. Section 9(3) makes it an offence for a person in Singapore to advertise on behalf of a provider that is not licensed or exempt. The publisher’s defence in section 9(6) does not cover someone who devised the advertisement’s content.
What statement must a licensed remittance company include in its ads?
MAS Notice PSN08 prescribes a statement that the firm is licensed by MAS to provide the named service, with a warning that this does not mean customers will recover all their money if the business fails. It must be in reasonable size and not obscured.
Do money-changers have to display exchange rates?
Yes. MAS Notice PSN07 paragraph 16 requires licensees to display prominently, before the customer uses the service, the exchange rate offered and any separate fee. Receipts must show the rate applied and the commission in Singapore dollars.
Can I advertise “zero fees” for transfers?
Only if the overall offer is not misleading. If the cost sits in the exchange-rate margin, a zero-fee headline beside a poor rate may mislead consumers. Show the rate customers will get and any conditions.
How do I check whether a provider is licensed?
Search the MAS Financial Institutions Directory for the exact legal entity and service, and check the MAS Investor Alert List. The alert list is not exhaustive, so a clean result there is not proof of a licence.
